M/S. MAERSK BV (FORMERLY KNOWN AS NEDLLOYD BV) C/O. MAERSK LINE INDIA PVT. LTD Vs. DY. DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION

JUDGEMENT

(1.) THIS appeal under Section 260-A of the Income Tax Act, 1961 (the Act) challenges the order dated 3 July 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). This appeal relates to Assessment Year 2003 -04.

(2.) BEING aggrieved, the appellant has raised numerous questions of law. However, the appeal is admitted only on the following substantial question of law which reads as under:-

(3.) THE appellant is a company incorporated in Netherlands and is a tax resident therein. The appellant is engaged in operation of ships in International water in partnership with M/s. Maersk Line UK Ltd. (formerly known as P & O Nedlloyd Ltd.), in the name and style of P & O Nedlloyd (PONP), a partnership in UK with a profit sharing ratio of 56:44 between Maersk Line UK Ltd. and the appellant.